Meta

Will Ashworth, a fellow blogger, wrote to me about the new ING mutual fund campaign. He thinks it’s misleading not to compare similar products.

I covered Streetwise on my blog . The one thing that isn’t discussed is the comparison ING uses in their marketing to highlight the benefits of Streetwise over other products.

They compare its 1% MER to 2.6% for the average balanced fund. That is traditional financial services marketing at its worst. They are comparing apples to oranges, passive to active. It’s completely misleading. I believe the product is a reasonable one. I just wish they would play fair in their marketing.

I found this an interesting argument, so I asked ING Direct for its comments. Here’s what I heard back from ING’s Paul McKenna.

Mr. Ashworth is entitled to his viewpoint. However, the Streetwise Funds are stand-alone balanced funds and we have made the direct comparison to the average MER for their peer category. Unless Mr. Ashworth doesn’t consider index funds to be mutual funds, the comparison is valid.

ING DIRECT is an advocate for saving and the intent of the comparison is to highlight how much Canadians pay in mutual fund fees and the impact the additional fees can have on the long-term growth of a investor’s portfolio. The Streetwise Funds provide investors with a low cost option with global diversification across stocks and bonds.

Within the index category we acknowledge that there are lower cost alternatives. However, depending on the distributor, they require the investor to be more involved in managing the portfolio than the Streetwise Funds do. One of these alternatives is a portfolio of ETFs that Mr. Ashworth proposes. Although the example that Mr. Ashworth uses on his website is accurate, he makes some assumptions that skew the analysis towards ETFs:

Mr. Ashworth assumes all investors pay $9.95 per trade to buy and sell the ETFs. This commission rate is one of the lowest available and is generally reserved for the most active traders or preferred clients with high balances. The everyday investor pays roughly $27 per transaction, based on the average of the posted commissions at the major discount brokerage firms (source: Investor Economics: The Retail Brokerage Report – Winter 2008).

He also assumes that the ETFs are bought and held for the five-year period without rebalancing (four Buys and four Sells only). The Streetwise Funds are rebalanced back to their original allocations on a quarterly basis. Even rebalancing the ETF portfolio once a year changes the cost structure significantly.

The final assumption is that the investor does not make any subsequent purchases or uses a dollar cost averaging strategy through regular monthly investments like an Automatic Savings Program offered by ING DIRECT, but a feature not available on brokerage accounts. Commissions would apply to each buy and sell of the ETFs.

The example also does not account for any account administration fees associated with RRSP accounts, which can add another $100 per year to the costs.

The low MERs of ETFs can be quite attractive for investors. However, most investors overlook the transaction costs and once you factor in commissions, rebalancing and other account related fees, ETFs can easily be a more costly alternative than the Streetwise Funds.

This response made Will Ashworth angry. He still wants ING to compare its new product to others that use the same investment strategy.

The real problem is that ING is using 2.6% as the benchmark MER for balanced funds in Canada. We should not be patting them on the back for this obviously manipulative manouevre.

Listen, if you came to me on the street and offered to sell me an iPod for 60% off the going price, I’d be crazy to turn you down. I don’t see how ING’s offer is any less enticing. However, in the case of Streetwise, you’re not actually getting 60% off.

Then, I asked Bylo Selhi to provide his views. While he’s an advocate of indexing, he’s also an independent thinker. Here’s what he said.

ING markets to relatively unsophisticated investors. These folks don’t likely have brokerage accounts, don’t know what rebalancing is, why they should do it, how to do it, etc., nor do they have the discipline to do it. Yes, charging 50 bp to rebalance on top of the ~50bp that TD charges on their eFunds seems high, but it’s half as much as what TD charges for the same service. (TD’s managed portfolios charge 1.25% to 1.5% for eFunds class.)

In addition, as Streetwise assets grow, it’s possible that ING will be able to pass some of the economies of scale back to investors by lowering the MERs. Consider that even at a 1% MER, ING needs to attract $1 billion in assets in order to generate $10 million in gross MER revenues. Out of that, they not only have to pay for fund management, client administration, regulatory costs, legal cost, etc., but they also have to pay for their launch marketing campaign. From a business point of view, 1% doesn’t seem that unreasonable, at least to start with.

As for me, I like the fact that a major financial institution is spending big bucks to tell Canadians about high MERs. But once ING gets that point across, I think it should also start advertising the fact that index funds have lower costs than actively managed funds and start comparing its MER with other similar products.

That would be playing straight with people who not only want to save their money, but to understand how they can save their money.

21 comments

I couldn’t agree more with Mr. Ashworth, comparing an index fund to a managed fund is apples and oranges.

While most Canadian investors would be better off with ING’s Streetwise offering rather than their current overpriced mutual funds, the fact is that TD has e-index funds that are less than half of 1% MER. Altamira Precision index series is also less than 1% MER.

Iâ€™m thrilled there is more choice for Canadian mutual fund investors in the index space with ING’s Streetwise. Does ING Direct offer the lowest index MERs with their Streetwise funds, NO. Are there more affordable options, YES.

But I must applaud ING’s mass publicity on the importance of MERs and the advantages to indexing. Yes I believe they are comparing apples to oranges, as Will Ashworth notes. However, the more Canadians consider costs, the better.

That’s a good synopsis of what we’ve been discussing. I hope your readers chime in with some excellent comments. It’s an important topic — lowering MERs — so I don’t want to take away from that. However, I do feel if ING wants to be a leader in this call to action, it needs to play fair.

ING is to be commended! However, the comments thus far have missed the key point.

Comparing Streetwise’s 1% fee to active management’s 2.6% is fair when considering this fact: passive investing beats active investing over time with consistency. Are there other ways of accessing passive management? Yes. Are ETF solutions more flexible and more powerful when properly constructed, managed and monitored regardless of the costs? Yes.

> comparing an index fund to a managed fund is apples and oranges
Is it? The rest of the industry, including BGI and their ETFs do the same. If you’re currently an investor you’re exposed to all the advertising from the fundcos behind those 2.6% MERs. That’s ING’s competition, not TD eFunds or Altamira. So naturally their promotions are based on what the vast majority of their prospective clients are actually paying for funds.

What’s really apples to oranges is that the “average” 2.6% MER funds include the cost of professional advice. If you actually get that advice then the comparison to low-MER funds, active or index, is indeed apples to oranges. Unfortunately many investors fail to get more than an annual phone call from an advisor who wants them to contribute to their RRSP.

BTW my pet peeve is that Canadian discount brokers won’t offer the lower-MER F-class variants of mutual funds which do not include the 1%-point of MER (for sales commissions and trailers) to pay for advice. This is particularly egregious considering that discount brokers aren’t allowed by securities legislation to provide advice. So why are they charging investors for something they can’t — even if they wanted to — provide? But I digresss…

> TD has e-index funds that are less than half of 1% MER
True, but you have to establish an asset allocation and then rebalance periodically. That may not be a big deal for you and me but I suspect it’s a daunting task for most of ING’s target audience.

> Itâ€™s an important topic â€” lowering MERs…
Absolutely! But bear in mind that ING, as well as the other index fund purveyors are in business to make a profit for their shareholders. (And that includes you if you happen to own a TSX index fund or ETF.)

As Ellen quoted me in the main article, at 1% ING would need to have $1B in assets in order to make $10M/year in revenue. Judging by the asset sizes of the two established Balanced index funds I linked to above, I doubt they have even $100M so far. So they now have at best $1M MER revenue stream to pay for running their Streetwise offerings. I can assure you there’s no way they can break even — let alone make a profit — on that piddly amount. (For comparison sake, PH&N’s Balanced Fund, MER of 0.86%, which has been around for 16 years has just under $1B in assets.)

Let’s have this conversation again if/when ING also has at least $1B in balanced fund assets.

I don’t have an issue with those that believe passive investing beats active investing hands down. There is quite a bit of anecdotal evidence to defend such a position.

However, don’t be so foolish to think ING is doing this out of concern for the Canadian investor. They are doing this solely because it is a good business decision. All they have to do is prove three things:

A) That passive investing makes sense for the average investor;
B) That Canadians pay too much in fees for little if any performance; and
C) Then show how cheap ING’s solution is to the rest of the industry.

It’s a great game plan.

ING – change the message when it comes to average Canadian Balanced Fund MER’s and you might even convince me to move some of my money. Fair is fair.

Bylo’s analysis sounds reasonable to me. ING is not making much money on Streetwise, and it may be a while before they do.

Don’t misread me, no business enterprise, let alone one that must answer to Dutch masters, is altruistic, so there must be a payoff somewhere. However, ING Bank Canada did move out of conventional mutual funds (they sold them to AGF two years ago if I recall correctly) and into Streetwise. The margins are likely similar to, or lower, than before given the trailers on the funds they were selling, so this move took some thinking.

You are absolutely correct in identifying the three arguments ING needs to make to be compelling:

A) Passive investing makes sense
B) Canadians pay too much for what they get in performance
C) ING’s solution is relatively cheap

But different audiences need different messages. Let’s consider (A).

For the academically inclined: Professor William Sharpe says that because the average passive return = the market return and the average active return = the market return, the only difference between them is costs. And because the cost of active management is higher with higher turnover, passive returns are greater than active returns.QED.

For the curious investor: The median Canadian Equity Balanced mutual fund (Globefund.com) had an annualized return for the 5 years ending March 31, 2008 of 9.7%, compared with 13.6% for a benchmark (60% S&P/TSX Composite + 40% DEX Universe) or 11.4% (40% S&P/TSX Composite + 10% S&P500 + 10% MSCI EAFE + 40% DEX Universe). Add 1.0% for fees, and the passive investor does reasonably well compared to the median Canadian Balanced Fund.

For the person on the street: The investor takes all the risk, the mutual fund company takes 21.5% of the return (based on 5 years for the median Canadian Equity Balanced Fund and the median fee of 2.66%) or 36.6% of the annualized return over ten years ending March 31, 2008. (The maximum casino “take” for slot machines is 25% in Nevada and 17% in New Jersey). Maybe not a fair comparison, but communication is what we are talking about.

As for (C), if ING were trying to woo existing passive investors, they should add some comparisons. But I suspect their larger audience are those poor folks who own the over $700 billion in mutual funds in Canada, many of whom would be better served with Streetwise and other passive alternatives.

One more “back of the envelope calculation.” At an average MER of 2.6%, that $700B in assets generates ~$18B in annual MER revenue. Now admittedly most of that goes to pay fund managers, for fund company administration, regulators, lawyers, GST, overheads as well as to pay financial planners’ commissions and trailers. But suppose that just 1% of that $18B goes into marketing. That’s a whopping $180 million a year. (No wonder one can’t avoid the constant barrage of fundco ads during RRSP season 😉 )

It’s that marketing muscle â€” virtually all of which has a vested interest in convincing Canadians that paying 2.6% in MERs for active fund management and professional financial planning beats DIY indexing â€” that ING has to market against. You have to give ING credit for trying to be heard above that level of marketing noise coming from their competitors.

Obviously, I’m in the minority here. It’s clear most people on this board feel ING is not being deceitful in their marketing. If anyone can provide statistics showing me that the $700 billion in mutual funds owned in Canada generates $18 billion in MER’s, I’ll eat my hat. If it is that high, it’s not because of balanced funds. The culprit would have to be the WRAP programs out there, which is a different beast altogether.

I still believe their marketing is misleading but that’s just my opinion. I’ve been wrong before.

Simple math Will. From The Investment Funds Institute of Canada, “Assets under management $687.6 billion” as of April 15, 2008. The average MER on those assets is 2.6%, so 0.026 x 687.6 = $17.85 ~=$18 billion.

If you dig deeper at IFIC’s website you’ll see that domestic balanced fund assets alone are $151.7B, so the MER revenue from them is 0.026 x 151 ~= $4 billion. Again, if only 1% of that is used for marketing, then that’s $40 million. That’s still a lot of money.

I think it’s fair ball and worthwhile for ING to compare itself to other balanced funds and tout its lower MER. It’s also fair for the rest of us to say that their fee could be even lower and it is entirely possible to do even better with the alternatives other commentors have mentioned.

ING Rebalancing once per quarter = too often, according to research that Rob Carrick covered a few months ago that showed e need for threbalancing every four years or so, or when asset classes diverge more than 5% from their policy target.

ING Portfolio Makeup / Asset Classes with TSX60, S&P500 = the couch potato portfolio for joe amateur; If we are to pay 1% for professional management, why can’t we include other than large cap equities, i.e. the total market, including small caps and value that provide more diversification, as well as emerging markets? And no foreign fixed income either? Four asset classes is too few. Take a look at IFA Canada for a much more sophisticated and all-inclusive portfolio at around the same net fees.

ING Servicing Account aka Advice: I’d love to know what advice a person actually gets. On the website, there is a mini questionnaire to assess the crucial question of risk tolerance and establish which mix of assets to hold in the fund. Is that worth the extra 0.5% MER compared to TD e-Series? There’s a curious statement in ING’s InvestorEd FAQ on fees. It says with respect to trailer fees, “This is how we are paid.” Does this mean that ING is actually not the fund company itself, is merely a remarketer of Templeton funds (whose outdated background material on diversification they use) with their own brand applied?

Bylo, your 2.6% figure is old (median is 2.3%) and not asset weighted (which would bring you down to 2% or slightly under).

Unlike most, I’m in the camp of those that feel ING has been a little misleading with its promotion of the Streetwise funds. I think the extra choice is great and they are well suited to certain investors but I expected ING to be more forthcoming in its marketing. I’m a big fan of the organization, I’m a banking and insurance client – have been for ten years – but was taken aback when I received the Streetwise brochure.

Here are my observations from a Streetwise brochure that was sent to my home.

1. It starts out fabulously by quoting “average balanced fund MERs” of Canada vs. eight other countries. First, the figures come from a draft research report, in which I poked many holes 18 months ago(http://www.danhallett.com/articles/09052006.shtml). Second, even if you accept the paper’s figures, with all of its weaknesses, the data they use is almost six years old. Finally, the “average” cited is a simple average, not a more representative dollar weighted average, which would show an average MER of about 2%.

2. The brochure goes on to quote from financial experts, which amount to a few journalists and a CFA charterholder employed by the manager of the Streetwise funds (State Street). Yet, my admittedly quick scan of the brochure didn’t uncover any disclosure that State Street is the funds’ manager. I found that out by looking in the prospectus.

3. Then, they have a bar chart showing the impact of fee differences between 2.6% and 1%. What’s missing is the bar chart showing the impact of fee differences between 1% and 0.3% (what it would cost to build an equivalent ETF portfolio). Wonder why that’s missing. 😉

4. Finally, the brochure boasts so-called facts that “they” [financial advisors] don’t want you to know about. Yet the prospectus offers to pay “them” up to 0.40% per year to sell the funds to clients if they’re not already insulted by their ads. Do people who buy direct get to keep that extra 0.4% they’re willing to pay to advisors? I didn’t see any indication of that.

I am curious about your weighted 2% and median 2.3% numbers. They don’t include ETF MERs, do they? Globefund monthly fund statistics offers summaries by category and it is difficult to find median MERs (except money market) much lower than 2.44% and they do include ETFs.

The Tufano, Servaes paper is old, but median US fund MERs are down 20% since then also.

Anyway, the bottom line is pretty much the same. Canadian mutual funds are very expensive and investors can do better.

1. The 2.6% MER for Canadian Balanced funds I used came from Morningstar via Google search. IIRC that page was a few years old too, but it’s not just Tufano et al who bandy that number about.

2. Fair point.

3. When was the last time you saw a brochure from the big fundcos that showed the impact of their 3% MERs compared to their low-MER competitors like PH&N? Why hold ING to a higher standard?

4. Same thing with the rest of the industry who tell the public how important it is to pay for advice yet sell their funds via discount brokers who aren’t allowed by securities regulators to provide advice? Remember what those same fundcos did when E*Trade tried to offer F-class funds? (And who made those fundcos gang up on E*Trade. It sure wasn’t the brokers.)

I’m not saying that ING and BGI marketing is as transparent as it should be. But why do you hold them to higher standards than those you explicitly accept from the rest of the industry?

My median and weighted average MER figures are for balanced funds. Other than the new Claymore ETFs, I am not aware of any balanced fund ETFs. TD does offer balanced index funds. But both groups have an insignificant impact on the median and the dollar weighted MER figures.

The paper by Tufano et al is old but there are a number of issues that aren’t obvious that muddy their numbers. I highlight many such issues in my articles (shown in my last post) but another is the fund-of-fund MERs. The authors say that the inclusion of these funds reduces average MERs because they don’t include fees of underlying funds. By the end of 2002, Canadian fund of funds indeed had to include in its published MER the fees of underlying funds. When you pick apart the country-specific nuances – which the authors did not do because it’s an enormous undertaking – the comparative numbers outside of North America are very uncertain.

1. The 2.62% figure in Morningstar’s June 2003 paper is a simple average. Again, everybody latched onto that figure – presumably because it’s higher – than to the more relevant 2.1% figure which takes assets into account and excludes seg funds.

3. I hold ING to a higher standard for two reasons. First, because their Streetwise campaign revolves around putting more jingle in your jeans. To illustrate their effort in this regard, they show an old inflated MER figure with a current number for their new product and show the comparison in their marketing material. They’re making fees a central part of their marketing. Load fund companies don’t do that. Second, your suggested comparison has one MER with advice included and one without. My suggested comparison is for the DIY investor. That’s apples to apples and I suggest it because it’s ING that chose to make a fee comparison in the first place.

4. That’s a fair point but would it be better if they didn’t sell through discounters at all? DFA does this and there are pros and cons to this approach. I agree that F class funds should be sold to discounters but there is a lot of choice already for DIY investors.

I hold ING and BGI to a higher standard because they claim to be more transparent. If that’s the claim, they should live up to it. When was the last time you heard Fidelity or CI claiming to be transparent and low fee? Also, promotions by ING and BGI are not scrutinized much, if at all, by most people because of their branding as low fee more transparent products. Yet the marketing spin is as spectacular as anything I’ve seen elsewhere in the fund industry.

By the way, I’m not great fan of industry advertising either. And I have been outspoken about some changes in the industry over the years that I thought were detrimental – such as the changes made to mutual fund disclosure a few years ago. I’m not on the side of load fund companies. I’m on the side of what I believe to be true and fair.

Thanks for the link to the Investment Executive article pursuant to the paper “Mutual Fund Fees Around the World.” Your points may be well taken, but it still appears that Canadians are getting shafted relative to other jurisdictions. Comments about Canadians getting “more choice” from the fund industry seems to ring hollow if the choices are not “better” ones. If the criticism of the industry in Canada was unjustified, then shame on those who provided information for the study (although I believe they are well intentioned individuals): Peter Bowen, Fidelity Canada, John Campea and Rudy Luuko, Morningstar Canada the University of Toronto and York University.

More interesting to me (and other Canadian investors perhaps) were the reasons offered to explain lower fee regimes by the paper’s authors:

1. Superior judicial systems (OSC and all those provincial commissions, are you listening?)
2. Higher per capita GDP (this shouldn’t be a problem should it?)
3. Better educated population (large adviser industry keeping clients stupid?)
4. Less concentrated banking sector (yikes! but I suppose Germany is worse))
5. Banks not allowed to enter the securities business (they dominate it in Canada through bank-owned brokerage firms and happen to control over 60% of funds distribution in the country!).

If Canadians are not well educated in financial matters (as implied by the paper) then the message should be kept simple: “Indexing and ETFs are good, mutual funds are bad.” I think that is what ING Bank is saying and I think it’s a pretty fair message.

What’s wrong exactly with an industry that has enough choice to allow do it yourselfers to build simple, broad-based index portfolios costing just 0.3% per year (less if accessing Vanguard and other ETFs)? DIY can put active portfolios together for 1% or less.

What exactly is wrong with this?

How many of the 18 countries studied by Tufano et al offer similar breadth of cheap products to allow DIYs to construct similarly cheap portfolios?

Nothing â€” if you’re a DIYer. The problem is that most Canadians aren’t.

IMO Streetwise’s marketing isn’t directed at traditional DIYers but rather at those who don’t invest at all, as well as those who feel intimidated by or who have had bad experiences with the conventional hidden commission/trailer sales model.

Streetwise (as well as TD’s and CIBC’s similar offerings) provide one stop, one fund investing for those who don’t really want to be DIYers yet who also don’t want to deal with advisors.

Choice (and the resulting competition) is good. Although, like you, I’d have liked to see lower MERs from Streetwise, I have no quarrel with them, especially as a start-up. Ask me again when their AUM crosses a $1B 😉

> DIY can put active portfolios together for 1% or less.

Actually they can do it for less than half that using TD eFunds, which are far more accessible to “small” investors than ETFs. They can also do it with actively-managed funds/portfolios from various no-load fundcos including PH&N.

> How many of the 18 countries studied by Tufano et al offer similar breadth of cheap products to allow DIYs to construct similarly cheap portfolios?

I’d venture that most, if not all, do. At least in Europe (which is all that I’ve looked at) low-cost ETFs are widely available to track country indexes like FTSE, DAX, etc. as well as various pan-European indexes. For everything else investors have exactly the same choice as Canadians, i.e. all the US-based ETFs that trade in New York.

*** Iâ€™d venture that most, if not all [of the 18 countries studied by Tufano et al offer similar breadth of cheap products to allow DIYs to construct similarly cheap portfolios]. ***

You are welcome to “venture” but you don’t know because you haven’t studied each of those country’s fund markets. And if you did, you may not have the disclosure of fees found in North America to ensure that you had an apples to apples comparison. Three academics didn’t do it so I’m assuming you haven’t either.

*** At least in Europe (which is all that Iâ€™ve looked at) low-cost ETFs are widely available to track country indexes like FTSE, DAX, etc. as well as various pan-European indexes. For everything else investors have exactly the same choice as Canadians, i.e. all the US-based ETFs that trade in New York. ***

I know this to be true so I agree with you but ETFs were not included in the study that everybody keeps quoting without delving into details. As you point out, every Canadian with a brokerage account can buy a U.S. total market ETF for 0.07% per year. If you can access these dirt cheap products, what do you care what the “average” is anyway.

Anybody who wants to bring the “average” down should stop buying high fee funds. But people don’t want to do that. In part, as you also highlight, most people aren’t DIY investors. Accordngly they want and/or need advice. This comes at a cost. Fee-only advisors actually get paid more in many cases than their commission-based peers so it’s not clear that transparency will reduce costs.

What will reduce costs is if investors become more comfortable not seeking and paying for advice. And I just don’t see that happening in a way that is widespread and sustained enough to bring down fees. But I wish firms like Steadyhand all the best in their efforts in this regard.

One thing with iShares is that you must buy whole units. Even distributions that result in fractional shares will mean you get cash, which will likely sit in your account until you can buy another whole unit. This is something that ‘regular MFs’ don’t have to worry about. How much will it cost you to buy 1 unit of an iShare?

Apples to oranges… either way, breaking it down to the simplest fact, ING is educating the public to ‘think twice’ when investing.

I’m sure everyone will agree that anyone contributing their thoughts to this article means that people are taking a financial interest in their future.